Filed Date: March 19, 2025
Case Ongoing
Clearinghouse coding complete
This case challenged the freezing of federal grant funds meant for green infrastructure projects. Plaintiffs—the California Infrastructure and Economic Development Bank (IBank), Efficiency Maine Trust, Illinois Finance Authority, and Minnesota Climate Innovation Finance Authority—filed a lawsuit in the U.S. District Court for the District of Columbia. The case was assigned the Judge Tanya S. Chutkan. The plaintiffs sued Citibank, the U.S. Environmental Protection Agency (EPA), and the EPA’s Administrator and acting Deputy. Plaintiffs sought an injunction and declaration, claiming the defendant's actions unlawfully blocked access to critical funds for climate-related projects, violating statutory and constitutional law.
The lawsuit arose from the administration of the Greenhouse Gas Reduction Fund (GGRF), a federal program within the Inflation Reduction Act, designed to provide financial support for clean energy projects. The Environmental Protection Agency (EPA) had selected three primary grantees in April 2024, including the Coalition for Green Capital (CGC), which subsequently awarded subgrants to IBank, Efficiency Maine, the Illinois Finance Authority, and the Minnesota Climate Innovation Finance Authority. These subgrant funds were held at Citibank under a Financial Agency Agreement (FAA) with the U.S. Treasury.
On January 22, 2025, each plaintiff executed an Account Control Agreement (ACA) with Citibank and CGC, outlining Citibank’s obligation to disburse funds according to the account holders' instructions. However, in February 2025, Citibank began refusing to process valid disbursement requests from the plaintiffs. Plaintiffs contend that Citibank acted at the direction of EPA officials, who sought to freeze funds based on alleged concerns about fraud and misuse—concerns that plaintiffs argued were unfounded. The EPA officials, plaintiffs claimed, acted pursuant to the Trump administration’s policy of “Terminating the Green New Deal” as stated in Executive Order 14154.
On March 19, 2025, the plaintiffs filed a complaint claiming the defendants violated the Administrative Procedure Act (APA) for acting contrary to law and uniform grant guidance, and for being arbitrary and capricious. They also claimed defendants committed equitable ultra vires actions outside the scope of the statutory authority of the executive branch. Plaintiffs also claimed defendants violated the Constitution for the Separation of Powers by usurping the legislative function, the Appropriations Clause, the Spending Clause, the Tenth Amendment, the Take Care Clause, and the Legislative Vesting Clause. The plaintiffs also alleged a violation of state contract law. Plaintiffs sought (1) a declaration that Citibank’s refusal to disburse funds violated the ACAs and federal law; (2) an injunction compelling Citibank to release the frozen funds; (3) an order barring federal defendants from directing or enforcing account freezes; and (4) damages for the financial harm caused by Citibank’s alleged breach of contract and conversion.
On March 24, the plaintiffs filed a motion for a preliminary injunction. In this motion, plaintiffs argued the defendants unlawfully withheld funds in violation of the APA, the Constitution, and the parties’ contractual obligations. This violation, they claimed, would lead to the imminent and irreparable injury of the plaintiffs. Defendant's response was required by March 31.
On March 25, Judge Chutkan ordered that this case be consolidated with Climate United Fund v. Citibank (1:25-cv-00698); Coalition for Green Capital v. Citibank, N.A. (1:25-cv-00735); Power Forward Communities, Inc. v. Citibank (1:25-cv-00762) Climate United Fund was named the lead case and all further filings were directed to be filed there. This Clearinghouse record is closed; see Climate United Fund v. Citibank for further developments.
Summary Authors
Jillian Snyman (3/25/2025)
Climate United Fund v. Citibank, District of District of Columbia (2025)
Coalition for Green Capital v. Citibank, N.A., District of District of Columbia (2025)
Power Forward Communities, Inc. v. Citibank, District of District of Columbia (2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69758448/parties/california-infrastructure-and-economic-development-bank-v-citibank-na/
McCombs, Theodore A.B. (District of Columbia)
Richards, Megan Anne (District of Columbia)
Allen, Kenneth Winn (District of Columbia)
McElroy, Saunders Lee (District of Columbia)
Sacks, Marcus S (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/69758448/california-infrastructure-and-economic-development-bank-v-citibank-na/
Last updated April 22, 2025, 1:09 p.m.
State / Territory: District of Columbia
Case Type(s):
Presidential/Gubernatorial Authority
Special Collection(s):
Trump Administration 2.0: Challenges to the Government
Trump Administration 2.0: Challenges to the Government (Spending Freezes/Cuts)
Trump Administration 2.0: Challenges to the Government (Environmental Protections)
Key Dates
Filing Date: March 19, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Plaintiffs are state green banks, public or quasi-public entities that provide crucial financial services to pollution-reducing projects in their States
Plaintiff Type(s):
Public (for-profit) corporation
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Citibank (South Dakota), Private Entity/Person
U.S. Environmental Protection Agency, Federal
Defendant Type(s):
Case Details
Causes of Action:
Ex Parte Young (Federal) or Bivens
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Declaratory Judgment Act, 28 U.S.C. § 2201
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Federalism (including 10th Amendment)
Spending/Appropriations Clauses
Available Documents:
Outcome
Prevailing Party: None Yet / None
Nature of Relief:
Preliminary injunction / Temp. restraining order
Source of Relief:
Content of Injunction:
Issues
General/Misc.:
Presidential/Gubernatorial Authority: